Transfer Pricing in Canada: The Transfer Pricing Penalties This blog post is also available in pdf format here. Legislation Since 1997, Canada’s transfer pricing rules have been included in section 247 of the Canadian Income Tax Act (ITA). They are complemented...

Transfer Pricing in Canada: Reasonable efforts to Determine an Arm’s Length Price This blog post is also available in pdf format here. Legislation Since 1997, Canada’s transfer pricing rules have been included in section 247 of the Canadian Income Tax Act...

Transfer Pricing in Canada: Contemporaneous Documentation This blog post is also available in pdf format here. Legislation Since 1997, Canada’s transfer pricing rules have been included in section 247 of the Canadian Income Tax Act (ITA). The Canadian transfer pricing rules...

Transfer Pricing in Canada: Reporting of Non-Arm's Length Transactions with Non-Residents This blog post is also available in pdf format here. Legislation Since 1997, Canada’s transfer pricing rules have been included in section 247 of the Canadian Income Tax Act (ITA)....

Finance Canada has released its Notice of Ways and Means Motion to introduce an Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting It is available here: https://www.fin.gc.ca/drleg-apl/2018/adtpfe-edipef-eng.asp. As it is...

Read our latest piece published in Intertax 45/12 titled “Contractual Arrangements and the Delineation of a Transaction: A Duo in Crisis Mode”. Summary - "This article highlights the evolving relationship between contractual arrangements and the delineation of a transaction for transfer...

The OECD recently released the comments received on its latest discussion draft on transactional profit splits in the context of the Base Erosion and Profit Shifting initiative (BEPS). These comments along with the comments received on the latest discussion draft on...

The OECD released its first discussion draft on the attribution of profits to permanent establishments in early 2001. Since then, quite a few updates have been released and can be found in the Library on BEPS and Transfer Pricing available here. Additional...

The OECD has just released new guidance on country-by-country reporting: Action 13: (Updated) Guidance on the Implementation of Country-by-Country Reporting Guidance on the Appropriate Use of Information Contained in Country-by-Country Reports The other documents and OECD guidance on country-by-country reporting are...

The BEPS phenomenon, as it is nowadays labelled by the OECD, is not new at all. In fact, the OECD was already talking about BEPS in 1986 with the releases of the Report on Thin Capitalisation and the Report on the...